2003 Activities

Legislation

The Energy Bill, which still hangs in the balance in the Senate, was a major focus of TAPS efforts this year. We actively lobbied as the bill progressed through the initial House and Senate consideration, and working hard through the Conference.

Lobbying on the electricity title of H.R. 4 was extremely intense, with electricity issues, including those in which TAPS was particularly involved, among the thorniest and most controversial issues in the conference negotiations. TAPS played a key role in working with the “anti-participant funding” coalition partners and committee staff.

TAPS negotiated a service obligation amendment with Southern Company and others that treated TDUs and transmission owners comparably, enabling us to successfully head off in both the Senate and Conference bill the House’s entirely unacceptable version.

We left our mark on a range of provisions, making the final language somewhat better from a TDU perspective than it would have been but for our efforts. Nevertheless, the final bill is, on balance, not desirable.

NERC

TAPS participated jointly with APPA in the NERC stakeholder group supporting legislation to create a self-regulating reliability organization under FERC supervision, a role that involved significant efforts to defend the language and negotiate changes that do not compromise the intent.

FERC

Standard Market Design Rulemaking (RM01-12)

TAPS Comments on Crucial Deferred Issues (filed January 10, 2003)
TAPS Comments on White Paper: FTR Issues (August 6, 2003)

Transmission Pricing Policy for Efficient Operation and Expansion of Transmission Grid (PL03-1)

TAPS Comments (filed March 12, 2003)

Market Behavior Rules (Docket No. EL01-118)

Comments of APPA and TAPS (August 18, 2003)
Reply Comments of APPA and TAPS (September 22, 2003)
Petition for Rehearing of APPA and TAPS (December 17, 2003)

Generator Interconnection Rulemaking (RM01-2/RM02-12)

TAPS Request for Rehearing of Large Generator Interconnection Rule (August 25, 2003) (focusing on comparability, participant funding, and preservation of network service)
TAPS Comments on Small Generator Interconnection Rules (October 3, 2003) (preserving position on rehearing)

Standards of Conduct (RM01-10)

Petition for Rehearing (December 24, 2003)

Critical Energy Infrastructure Information (RM02-4 and PL02-1) and related Amendments to Conform Regulations with Order No. 630 (CEII Final Rule) (RM03-6), TAPS efforts culminating in orders more accommodating of our information requirements than had been proposed.

TAPS Petition for Rehearing of CEII Rule, Rule 630 (March 21, 2003)
Joint TAPS/APPA Comments on Amendments NOPR, attaching supporting RW Beck paper (May 16, 2003)
TAPS Motion to Supplement and for Reconsideration of CEII Rule (May 27, 2003) (attaching May 16 Joint Comments in Amendments NOPR)